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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Assets held on 6/4/65: limit of period of apportionment

TCGA92/SCH2/PARA16 (6)The period of ownership over which the appreciation or depreciation of value is to be spread should in no circumstances be taken to begin before 6 April 1945. That means that the denominator of the time-apportionment fraction must in no case be greater than twenty years plus the period between 6 April 1965 and the date of disposal. This does not mean that the market value of the asset on 6 April 1945 is in any way relevant; the gain or loss (before the time-apportionment formula is applied) should be computed in the normal way by reference to the actual allowable expenditure.